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What Are the USDA Requirements for Packaging Film?

October 20, 2010
Question 

I have been asked by a client to provide a letter certifying that a packaging film complies with USDA regulations. Do any USDA regulations pertain to packaging materials? It has been my understanding that packaging materials come under FDA regulations.

Answer 

U.S. Department of Agriculture (USDA) regulations on packaging materials for animal and animal products can be found in Title 9 of the Code of Federal Regulations (C.F.R.) Section 317.24. These regulations requires a supplier to guarantee that the packaging material complies with the Food Drug and Cosmetic Act (FD&C Act) and all applicable food additive regulations. This regulation also states that such guaranties must identify the packaging materials and conditions of use and must be signed by an authorized official of the supplying firm.

Several options are available to satisfy the USDA Food Safety and Inspection Service's (FSIS) requirement on guaranties that packaging suppliers for meat and poultry products must provide. These include: a form developed along the lines set forth in Section 303(c)(2) of the FD&C Act; a letter from the supplier to its customer advising that the packaging material in question is in compliance with the FD&C Act and all applicable FDA food additive regulations; or confirmation from a third party, such as legal counsel. For more detailed information, see the Packaginglaw.com article, Customer Assurance for Food Packaging Materials: Points to Consider.